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Full text of "Board of Supervisors : ten selected organizations did not use city funds for political purposes"

SAN FRANCISCO PUBLIC LIBRARY 



3 1223 08514 6547 




San Francisco Public Library 

Government Information Center 
Ban Francisco Public tlbrary 
100 Laririn Street. 5tti Floor 
San Franciscu, CA 94102 

REFERENCE BOOK 

Not to be taken from the Library 



BOARD OF SUPERVISORS 

Ten Selected Organizations Did 
Not Use City Funds for Political 
Purposes 




GOVERNMENT 
DOCUMENTS DEPT 

FEB 2 7 2009 

SAN FRANCISCO 
PUBLIC LIBRARY 




February 25, 2009 



BOARD OF SUPERVISORS: 

Ten Selected Organizations Did 
Not Use City Funds for Political 
Purposes 



GOVERNMENT 
DOCUMENTS DEPT 

FEB 2 7 2009 

SAN FRANCISCO 
PUBLIC LIBRARY 




February 25, 2009 



CONTROLLER'S OFFICE 
CITY SERVICES AUDITOR 

The City Services Auditor was created within the Controller's Office through an amendment to the 
City Charter that was approved by voters in November 2003. Under Appendix F to the City Charter, 
the City Services Auditor has broad authority for: 

• Reporting on the level and effectiveness of San Francisco's public services and 
benchmarking the city to other public agencies and jurisdictions. 

• Conducting financial and performance audits of city departments, contractors, and functions 
to assess efficiency and effectiveness of processes and services. 

• Operating a whistleblower hotline and website and investigating reports of waste, fraud, and 
abuse of city resources. 

• Ensuring the financial integrity and improving the overall performance and efficiency of city 
government. 

The audits unit conducts financial audits, attestation engagements, and performance audits. 
Financial audits address the financial integrity of both city departments and contractors and provide 
reasonable assurance about whether financial statements are presented fairly in all material aspects 
in conformity with generally accepted accounting principles. Attestation engagements examine, 
review, or perform procedures on a broad range of subjects such as internal controls; compliance 
with requirements of specified laws, regulations, rules, contracts, or grants; and the reliability of 
performance measures. Performance audits focus primarily on assessment of city services and 
processes, providing recommendations to improve department operations. 

We conduct our audits in accordance with the Government Auditing Standards published by the U.S. 
Government Accountability Office (GAO). These standards require: 

• Independence of audit staff and the audit organization. 

• Objectivity of the auditors performing the work. 

• Competent staff, including continuing professional education. 

• Quality control procedures to provide reasonable assurance of compliance with the auditing 
standards. 



Audit Team: Elisa Sullivan, Audit Manager 

Houman Boussina, Associate Auditor 



3 1223 08514 6547 




City and County of San Francisco 

Office of the Controller - City Services Auditor 



Board of Supervisors: 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 



February 25, 2009 



Purpose of the Audit 

We conducted this review to meet the San Francisco Administrative Code (Administrative Code) requirement that 
the Controller annually audit at least 10 persons or entities that enter contracts, grants, or loan agreements with 
the City to ensure that they comply with Chapter 1 2G of the Administrative Code, which prohibits the use of city 
funds for political activity. 



Highlights 



Controller's Office 



Recommendations 

The audit report includes 13 
recommendations for ensuring 
that city departments and some 
organizations comply with 
contract terms and city rules and 
regulations. Specifically: 

• MOCJ should work with the 
Ethics Commission and 
Controller's Office to 
determine whether an 
employee's outside work 
inappropriately benefitted a 
contractor. 

• DCYF and MOCJ should 
ensure that all agreements 
incorporate the City's 
required agreement 
provisions. 

• JPD should ensure that its 
agreements do not include 
contradictory terms and that 
agreement amounts are 
consistently and accurately 
stated. 

• SFAA should properly 
invoice the City for actual 
and eligible expenses. 

• DBI, Rent Board, and JPD 
should establish wntten 
policies and procedures for 
reviewing invoices. 

Copies of the full report may be obtained at: 
City Hall. Room 316 • 1 Dr Carlton B Goodlett Place • San Francisco. CA 94102 • 415 554 7500 
or on the Internet at http //www, sfaov pro/controller 



All ten organizations that were the subject of this audit did not use 
city funds to participate in, support, or attempt to influence a 
political campaign for any candidate or ballot measure. 

However, we found that some organizations and city departments 
did not always comply with city rules or contract and invoicing 
requirements. In particular: 

An employee of the Mayor's Office of Criminal Justice (MOCJ) 
engaged in outside employment that is potentially incompatible 
with her job duties. 

The Department of Children, Youth and Their Families (DCYF) 
and MOCJ used abbreviated grant agreements that did not 
include important provisions. 

A Juvenile Probation Department (JPD) agreement had 
contradictory terms and a significant error in wording. 

San Francisco Apartment Association (SFAA) did not invoice the 
City for accurate amounts under the agreement we reviewed. 

Department of Building Inspection (DBI), the Residential Rent 
Stabilization and Arbitration Board (Rent Board), and JPD did not 
properly review invoices submitted by organizations prior to 
making payments. 



Page intentionally left blank. 




CITY AND COUNTY OF SAN FRANCISCO 



OFFICE OF THE CONTROLLER Ben Rosenfield 

Controller 



Monique Zmuda 
Deputy Controller 



February 25, 2009 

Board of Supervisors 

City Hall, Room 244 

1 Dr. Carlton B. Goodlett Place 

San Francisco, CA 94102 

President and Members: 

The Controller's Office. City Services Auditor, presents its audit report of 10 organizations and their 
compliance with the City and County of San Francisco (City) ordinance prohibiting the use of city 
funds for political activity. The audit revealed that the 10 organizations selected for review did not 
use for political activity any of the city funds received under grants, contracts, and loans with various 
city departments. 

We conducted this review to meet the San Francisco Administrative Code (Administrative Code) 
requirement that the Controller annually audit at least 1 persons or entities that enter contracts, 
grants, or loan agreements with the City. The Controller seeks to ensure that the persons or entities 
comply with Chapter 12G of the Administrative Code, which prohibits the use of city funds for 
political activity. The Administrative Code defines political activity as participating in, supporting, or 
attempting to influence a political campaign for any candidate or ballot measure. 

During the course of our audit, we found that some city departments and organizations did not 
always comply with city rules or contract and invoicing requirements. We discovered that a city 
employee engaged in outside employment that is potentially incompatible with her job duties. Also, 
some city department agreements did not include the required agreement provisions, and one 
agreement included contradictory terms and a significant error in wording. Further, we found that not 
all organizations properly invoiced the City for reimbursements, and that reimbursement requests 
are not always adequately reviewed by departments prior to making payments 

The audit includes 13 recommendations for ensuring that departments and organizations comply 
with contract terms, contracting best practices, and city rules and regulations Responses to the 
audit are attached as Appendix B We did not require responses from departments or organizations 
to which no recommendations are addressed. 

We appreciate the assistance and cooperation that the organizations' staff and staff in city 
departments provided during the audit 

Respectfully submitted. 



Ben Rosenfield 
Controller 



415-554-7500 City Hall • 1 Dr Carlton B Goodlett Place • Room 316 • San Francisco CA 94102-4694 FAX 415-554-7466 



Mayor 

Board of Supervisors 
Civil Grand Jury 
Budget Analyst 
Public Library 



TABLE OF CONTENTS 



Introduction 



Audit Results 3 

Appendix A - Summary of Agreements A-1 

Appendix B - Audit Responses B-1 



LIST OF ACRONYMS 



CSA Office of the Controller, City Services Auditor Division 

DBI Department of Building Inspection 

DCYF The Department of Children, Youth and Their Families 

HIFY Health Initiatives for Youth, Inc. 

JPD Juvenile Probation Department 

MOCJ Mayor's Office of Criminal Justice 

MOU Memorandum (or Memoranda) of Understanding 

SFAA San Francisco Apartment Association 

SFPT San Francisco Parks Trust, Inc. 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



INTRODUCTION 



Audit Authority 



Chapter 12G of the San Francisco Administrative Code 
(Administrative Code) requires the Office of the Controller 
(Controller) to annually audit at least 10 persons or entities 
that enter contracts, grants, or loan agreements with the 
City to ensure compliance with the prohibition on the use of 
city funds for political activity. 



Background 

The Administrative Code of 
the City and County of San 
Francisco prohibits the use of 
city funds for political activity 



The prohibition on the use of city funds for political activity 
became part of the Administrative Code after voters in the 
City and County of San Francisco (City) passed Proposition 
Q on November 5, 2002. The former proposition is now 
Chapter 12G of the Administrative Code, which defines 
political activity as participating in, supporting, or attempting 
to influence a political campaign for any candidate or ballot 
measure. Chapter 12G also requires that all city contracts, 
grants, and loan agreements disclose the prohibition. 



Objective 



The purpose of this audit was to determine whether any of 
the 10 selected organizations inappropriately expended any 
city funds participating in, supporting, or attempting to 
influence a political campaign for any candidate or ballot 
measure. 



Scope and Methodology 

Ten organizations were 
selected for review with the 
assistance of audit analytic 
software 



To select the 10 organizations, we obtained from the City's 
financial systems a list of organizations that were paid city 
funds under contracts, grants, and/or loan agreements 
during the period from July 1, 2006, through June 30, 2007. 
We also obtained databases containing records of 
contributions made to political groups active in the City and 
in the State of California. 



Using an audit analytic software program, we searched for 
matches between the names of organizations receiving city 
funds and the names of organizations that made 
contributions to political groups. We summarized and 
grouped the matched database records by organization and 
made a final selection of 10 organizations for our audit to 
include: 



At least one for-profit organization 

At least one organization that received funding 

under each of the three agreement categories 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 



specified in the Administrative Code (contracts, 
grants, and loans) 

Organizations that received various levels of funding 
from the City 



| Ten Organizations Selected for Political Activity Audit 


Organization 


Type 


Category 


Funding Received 


Asian, Inc. 


Non-profit 


Grants 


$ 67,885 


Bridge Housing Corporation 


Non-profit 


Contract, Loan 


1,897,868 


Health Initiatives For Youth, Inc. 


Non-profit 


Grants 


45,250 


Low Income Investment Fund 


Non-profit 


Grant 


2.633,931 


San Francisco Apartment 
Association 


Non-profit 


Grant, Contract 


57,948 


San Francisco Bicycle Coalition 


Non-profit 


Grant, Contract 


54,087 


San Francisco Parks Trust, Inc. 


Non-profit 


Grants 


8,500 


Transgender Law Center 


Non-profit 


Grant 


6,525 


Tsang Architecture 


For-profit 


Contract 


159,944 


Vanguard Public Foundation 


Non-profit 


Grant 


38,467 



Note: Funding is the amount the City and County of San Francisco paid, or loaned to the Organization from July 1. 2006, 
through June 30, 2007. 

Source. City and County of San Francisco Vendor Report 

To conduct the audit, we first verified that each organization 
had an agreement with the City that included the prohibition 
of using city funds for political activity, and other language 
consistent with contracting best practices for city 
departments. We assessed invoices submitted by the 
organizations, reviewed financial statements and 
accounting records, and verified payments that the City 
made to each organization from July 1, 2006, through June 
30, 2007. We also evaluated each organization's 
procedures for invoicing city departments under its 
contract(s), and asked the organizations' officers whether 
they had spent city or other funds for purposes related to 
political activity. In the course of performing the audit, we 
noted any deviations from contract requirements, city rules, 
and accounting best practices. Appendix A summarizes the 
agreements that were the subject of our audit. 



We conducted this performance audit in accordance with 
generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to 
obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained 
provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



AUDIT RESULTS 



The Ten Organizations 
Selected Did Not Use City 
Funds for Political 
Purposes 



All ten organizations that were the subject of this audit did 
not use city funds to participate in, support, or attempt to 
influence a political campaign for any candidate or ballot 
measure. In reviewing each organization's reimbursement 
requests and financial records, we found no evidence of 
political expenses paid for with city funds. We also obtained 
written management representation from each organization 
certifying that no city funds were used for political activity. 



Organizations and 
departments did not always 
comply with City rules, or 
contract and invoicing 
requirements 



The audit disclosed that some organizations and 
departments did not always comply with certain city rules or 
contract and invoicing requirements. We also found 
opportunities to improve related processes by 
implementation of best practices. Specifically, we found 
that: 

• A city employee engaged in outside employment that is 
potentially incompatible with her job duties. 

• Agreements with city departments were not always 
drafted using best practices in contracting, as 
exemplified in the City's boilerplate grant agreement. 

• Some organizations did not invoice actual expenditures 
and did not provide adequate supporting documentation 
for their expenditures. 

• Some city departments did not adequately monitor or 
review grantee invoices prior to making payments. 



A City Employee 
Engaged in Outside 
Employment 
Incompatible With Her 
Job Duties 



A full-time grant administrator at the Mayor's Office of 
Criminal Justice (MOCJ) performed potentially incompatible 
job duties as a consultant for Vanguard Foundation 
(Vanguard), one of the organizations we selected. 
Moreover, the employee did not disclose income she had 
received from Vanguard in Form 700, Statement of 
Economic Interests, which requires disclosure of additional 
income sources. Employees filing Form 700 are required to 
certify the disclosures made under penalty of perjury under 
the laws of the State of California. The Mayor's Office has 
confirmed that MOCJ was not aware that the grant 
administrator engaged in work apart from her duties at 
MOCJ. According to Vanguard's director of operations, the 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 

consultant engages in activities to improve Vanguard's 
grant administration and grant templates. She also provides 
advice on promoting Vanguard's programs to potential 
donors. 

According to Civil Service rules, city employees should not 
engage in work that is inconsistent or incompatible with 
official or assigned duties. Further, employees are 
prohibited from participating in paid work that may reflect on 
the honor or efficiency of the city service or may be contrary 
to the best interests of the City in any respect. Although city 
employees may be allowed to engage in other outside 
employment, with certain restrictions and requirements, 
MOCJ's deputy chief of staff was not aware of any specific 
permission given to this employee for engaging in outside 
paid work. 

Although MOCJ has not yet confirmed all details of the 
employee's employment, there is the appearance that the 
MOCJ grant administrator has violated Civil Service 
Commission Rule 1 18 by giving Vanguard an unfair 
advantage in conducting business and obtaining grants 
from the City. Based on a review of Vanguard's records and 
the individual's beginning employment date with the City, 
we found that she was paid $10,138 by Vanguard while 
employed at MOCJ. We also determined that Vanguard 
received approximately $70,000 1 in city grant funds during 
the period from July 1, 2007, through June 30, 2008, when 
the individual was a paid consultant at Vanguard. The 
Controller's Office will review the grant award process 
under which Vanguard received its contract with the City to 
determine whether the individual's work experience as a 
MOCJ grant administrator, and her access to the City's 
systems, may have given Vanguard an unfair advantage in 
doing business with the City. 

Subsequent to the audit A Mayor's Office director has confirmed that the employee 

acknowledged her employment with Vanguard. Further, the 
director stated that, for budgetary reasons unrelated to the 
potential conflict of interest matter, the employee was to be 
separated from city employment in mid-December. 



1 As noted in Appendix A, grant funds were paid to Vanguard under an agreement with the Juvenile Probation 
Department. 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



Recommendations 



The Director of MOCJ should: 



Two City Departments 
Used Abbreviated 
Agreements That Did Not 
Include Important Grant 
Provisions 



1 . Work with the Ethics Commission to determine the 
proper roles MOCJ and the Controller's Office should 
take in an investigation of the potential conflict of 
interest. 

2. Work with the Controller's Office to determine the 
degree to which the individual's work experience as a 
MOCJ grant administrator and her access to the City's 
systems may have given Vanguard an unfair advantage 
in doing business with the City. 

3. Work with the Department of Human Resources to 
determine if a restriction can and should be placed on 
future employment of the employee with the City. 

4. Remind employees of the requirement to disclose any 
outside employment and potential conflicts of interest. 
Employees should be reminded of penalties under 
perjury laws and Civil Service rules if required 
disclosures are not made. 

The Department of Children, Youth and Their Families 
(DCYF) and MOCJ used abbreviated grant agreements 
when contracting for services with Health Initiatives for 
Youth, Inc. (HIFY) and the San Francisco Parks Trust. Inc. 
(SFPT), respectively. These agreements lack most of the 
City's boilerplate grant agreement language, such as the 
prohibition on expenditures of city funds for political activity. 
Also, the MOCJ agreement we reviewed does not include 
some basic contract terms, such as an effective date and 
termination date, which normally indicate the period of time 
during which services are to be provided. 

The City's boilerplate grant agreement, known as the G- 
100, contains provisions that incorporate the City's social 
and other policies designed to uphold the interests of the 
City. The following are examples of policy areas addressed 
in the G-100: 



Non-discrimination in benefits 
Requiring minimum compensation for employees 
Prohibition of political activity with city funds 
Drug-free workplace policy 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 



The G-100 also addresses important basic agreement 
terms, such as the definition of eligible expenses and 
contract duration. Although city departments are not 
required to use the boilerplate, it is made available to them 
with instructions on usage. The use of the boilerplate helps 
to ensure that contracting best practices are adhered to by 
city departments that may not have in-house expertise in 
this area. According to a DCYF director, DCYF had a 
practice of issuing Memoranda of Understanding (MOUs) 
without the City's standard contract clauses because it was 
more efficient to do so, given the volume of agreements it 
administers. A MOCJ Program and Policy Associate 
(Associate) explained that MOCJ's practice has been to 
issue "mini-grants" to award small monetary amounts. The 
Associate is not aware of any policy regarding the use of 
abbreviated agreement documents, instead of the G-100. 

Due to the lack of a grant effective date and duration in the 
MOCJ grant, the period during which SFPT should have 
performed its services is unclear. MOCJ paid SFPT S2.500 
to hold Tai Chi classes under an agreement dated 
September 20, 2006. However, according to a SFPT 
representative, SFPT did not hold any classes until March 
2008. Moreover, although the agreement with MOCJ 
requires that SFPT submit a final report to MOCJ within 30 
days of project completion, to provide evidence of grant- 
related expenditures, the project completion date isn't 
specified. Consequently, as of July 2008, SFPT has not 
submitted any reports or supporting documentation to 
MOCJ, and most of the services paid for under the 
agreement have not been provided. 



Recommendation 



DCYF and MOCJ should ensure that all agreements, 
regardless of the monetary amount and complexity of 
the services contracted for. incorporate the City's 
boilerplate agreement language. 



The Agreement Between 
Vanguard Public 
Foundation and the 
Juvenile Probation 
Department Includes 
Contradictory Terms 



The agreement between Vanguard and Juvenile Probation 
Department (JPD) is unclear and includes contradictory 
terms. Although the agreement states that Vanguard should 
send to JPD an itemized list of eligible expenses for which 
grant funds are requested, together with supporting 
documentation such as invoices, copies of canceled 
checks, and payroll register reports, it also includes a 
statement that Vanguard will invoice JPD a fixed amount 
each month. In practice, Vanguard submits work plans and 
invoices with a fixed amount to JPD via an electronic 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



The agreement contains a 
significant error in wording 



reporting system, but does not include supporting 
documentation. Therefore, JPD cannot be assured that the 
expenses submitted for reimbursement are valid, eligible 
expenses for the month submitted. 

The agreement also incorrectly states that Vanguard may 
invoice JPD S58.500 each month 2 . This would deplete in 
one month almost the entire agreement amount of S65.000. 
which is meant to pay for year-round programs. In practice. 
Vanguard has been invoicing one-twelfth of 90 percent of 
the total agreement amount (approximately S5.000) during 
each invoice period, and the wording in the agreement is in 
error. 



Recommendations 



JPD should: 



Amend the agreement with Vanguard to clarify the 
terms. 

Not include provisions in its agreements that allow 
invoicing of a fixed dollar amount each period, but 
instead require submission of invoices and supporting 
documentation for actual expenditures that qualify for 
reimbursement. 



San Francisco Apartment 
Association Did Not 
Invoice Actual 
Expenditure Amounts 



8. Ensure that all agreement amounts are consistently and 
accurately stated. 

San Francisco Apartment Association (SFAA) did not 
properly invoice the Department of Building Inspection 
(DBI), or the Residential Rent Stabilization And Arbitration 
Board (Rent Board), for actual expenses incurred, as 
required under the agreement terms. All line items in the 
invoice submitted to the Rent Board were rounded to the 
nearest hundred or thousand dollar, and the invoices to DBI 
were for identical amounts for the four periods for which 
they were submitted. In addition, for all invoices, the 
amounts were not supported by adequate documentation of 
expenditures eligible for reimbursement. 



The grant agreement with the Rent Board specifies that 
eligible expenses are those incurred by SFAA in providing 
required services under the agreement. It also specifies 
that supporting documents are to be provided for each 
eligible expense. Similarly, SFAA's contract with DBI 
specifies that SFAA needs to provide reports or services for 



2 The exact coi n)e slates that Vanguard will bill JPD one-twelfth of 'JO percent, or S58.500 every 

month, with 10% held in reserve pending meeting all agreed-upon perfoi 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 



approval before invoices can be paid. According to SFAA's 
executive director, the sum of expenditures in supporting 
documents submitted with invoices to the Rent Board and 
DBI do not necessarily match invoiced amounts; they 
represent expenditures for various programs run by SFAA 
that also fulfill obligations under its agreements with DBI 
and the Rent Board. SFAA's Government and Community 
Affairs Director indicated that SFAA has recently revised its 
invoicing process, so that invoices and supporting 
documents more specifically reflect the portion of program 
expenditures eligible for reimbursement under the terms of 
its agreement with DBI. 

Though our review encompassed payments made under an 
agreement with DBI for $50,000 and an agreement with the 
Rent Board for $20,000, we noted that, from 1999 through 
2008, several city departments paid a total of $573,645 to 
SFAA. A review of those payments is beyond the scope of 
this report; however, given the City's ongoing business 
relationship with SFAA, it is important for city departments 
to obtain assurance that they are reimbursing only the 
specific portion of SFAA program expenditures eligible for 
reimbursement, and that they are not reimbursing the same 
expenditures more than once, or making duplicate 
payments. 



Recommendation 



9. The SFAA should resubmit appropriate supporting 
documentation for invoices submitted to the DBI and 
the Rent Board under the agreements reviewed, and for 
agreements active during at least the prior two years. 



Three City Departments 
Did Not Properly Review 
Invoices Prior to Making 
Payments 

The Department of Building 
Inspection and the Rent 
Board did not properly review 
invoices submitted by San 
Francisco Apartment 
Association 



We could not find evidence that DBI, the Rent Board, or 
JPD properly reviewed invoices prior to making contract or 
grant payments. 

A recently prepared reconciliation of invoices submitted by 
SFAA to DBI shows that invoiced amounts cannot be 
properly reconciled with supporting documentation 
submitted by SFAA. According to a DBI senior 
administrative analyst (analyst), there is no evidence that 
DBI staff did formal reconciliations of SFAA invoices with 
any of the supporting documentation prior to paying the 
invoices. DBI management states that, for their current 
agreement with SFAA, they have established a more forma! 
and detailed review process to verify invoices submitted by 
SFAA, and that they are in the process of establishing 
policies and procedures covering financial and 
administrative processes. 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 

According to a Rent Board representative, the Rent Board 
does not do a detailed review of the invoices submitted by 
SFAA. and does not take steps to ensure that invoiced 
amounts are properly supported by evidence of eligible 
expenditures. The representative further stated that the 
Rent Board currently does not have written policies and 
procedures or in-house expertise for the review of grant 
invoices. 



Monitoring procedures should 
be established to ensure that 
reimbursements are made for 
eligible expenditures only 



Because an adequate review process has not been in 
place, the Rent Board and DBI do not have adequate 
assurance that all amounts paid to SFAA were for eligible 
expenses under the terms of their respective agreements. 
The DBI and the Rent Board have made payments to SFAA 
under other agreements as well. From 1999 through 2008, 
DBI and the Rent Board made S354.543 and S69.495, 
respectively, in payments to the SFAA. 



The Juvenile Probation 
Department did not verify 
invoices prior to making 
payments 



JPD has not required Vanguard to submit supporting 
documentation for invoices it has paid, and it does not have 
a formal review process to ensure that invoiced amounts 
reflect actual eligible expenditures under the terms of the 
agreement. According to a JPD Director, JPD does a yearly 
site visit of Vanguard's activities at JPD's own site at Log 
Cabin Ranch 3 , but due to staffing shortages it does not 
review supporting documentation for grant funding 
requests. 



As a result, Vanguard invoiced a fixed dollar amount each 
month, as specified in the agreement, but did not provide 
any supporting documentation for JPD to verify the 
accuracy of the amounts, and to ensure that only eligible 
expenditures were reimbursed. 



Recommendations 



The Rent Board, DBI, and JPD should: 



10. Establish written policies and procedures for the review 
of grant invoices. 

1 1 . Review all invoices submitted by organizations 
requesting grant funding to ensure that evidence of 
eligible expenditures is provided prior to making 
payments. 

12. Review payments made under all departmental 
agreements in effect for at least the past two years to 



5 Log Cabin Ranch is a JPD post-ad|ud 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 



ensure that inappropriate payments were not made. 

13. Require grantee organizations to refund any reimbursed 
amounts that are improperly supported or unnecessary 
to achieve agreement goals. 



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Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



APPENDIX B: AUDIT RESPONSES 
MAYOR'S OFFICE 



Office of die Mayor $2851 r- • m 

„.. , . . . . 7 &SSB2MB Gavin Ncwsom 




January 13, 2009 



Ben Rosenfield 
Controller's Office 
City Hall. Room 316 
I Dr Carlton B. Goodlclt PI 
San Francisco, CA 94102 



Dear Mr. Rosenfield; 

The Mayor's Office has reviewed the findings in the Controller's Office Prop. Q draft report. Wc 
are concerned with the finding of a Mayor's Office employee having outside-City employment 
that is potentially incompatible with her City job duties. 

( ).:r current personnel practices educate all new employees for the need to disclose all outside 
investments or work -hat would potentially conflict with theirjob responsibilities in the Mayoi i 
office. Statements of Economic Interest are collected e\ ery ) ear from all Mayor's Office staff. 
However, wewiJl further emphasize with new and current Mayor's Office staff the need for full 
financial disclosure, the ileal to avoid conflicts of interest with theirjob duties, and the penalties 
I'.i /iolatjng perjury lows or Civil Service rules. 

Sincerely, 



'Julian Low 

Director of Operations 



■ 

^ " i . • 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 

DEPARTMENT OF CHILDREN, YOUTH AND THEIR 
FAMILIES 



DEPARTMENT OP CHILDREN. 




Gavin Newsom 
Mr :: 



Margaret Brodkin 



YOUTH AMD THEIR FAMILIES 



January 9. 2009 



Ben Roseufield. Controller 
City Hall, Room 516 
1 Dr. Carlton B Goodlert Place 
San Francisco. CA 94102 

Dear Ben Rosenfield: 

I am writing a formal response letter to nddiess the findings from the audit performed by your staff for 
the following agencies: Health Initiatives for Youth and the San Francisco Parks Trust Inc. 

DC YF used Memorandums of Understanding with the above agencies to giant small amounts of money 
or very hunted services. Each MOU was written with specific deliverables for the services, 
disbursement procedures and documentation for the completion of services within a beginning and 
ending time period. 

In response to the Controller's findings with the audit of Health Imtiatives for Youth and San Francisco 
Parks Tnist. Inc.. beginning Italy 1 2009 The Department of Children, Youth and Their Families 
<DCYF> will follow the recommendation that all agreements regardless of the monetary amount and 
complexity^ of the services contracted for will incorporate the City's boilerplate agreement language. 

DCYF wants to ensme that the City's policies and procedures around granting dollars to nonprofits for 
particular services are followed. Thank you fbi bringing tins important matter to our attention and for 
the recommendation 

Sincerely. 

It'iniia Haifa 



Winna Davis. Director of Programs and Grants 



Cc Houman Boussina 
Margaret Brodkin 

September Tarrett 



et Street Suite 900* San Fraaasco.CA 94 102 *Te • ■ ■•[;.(:■ I .S47 *w»w dcvf.org 



B-2 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



JUVENILE PROBATION DEPARTMENT 



> r ^ City aud County ot san i-rancisco vtillu.mpsiffirjia.yn 

ti*lA0: Juvenile Probation Department Chief Probation Office! 



BenRoseafield 
Controller's Office 
City HfilL Room 316 

1 Dr CarltouD CocdlettPl 
San Francisco l.-. 94102 



Deai Mi F.o ; eiifield 

The SF Juvenile Pi obanon Department acknowledges the work of the C orrro.ler s C ity Services Audit A a?r 
report for tlie purposes >f nakmg «ue select Community Based U; gamzations .. id not u-:e L'Ky funds for Political 
activities T.ie conducted renew included Vanguard Public Foundation a Qoo-profit agen rts with 

the SF Juvenile Probation Department. The findings concluded there were no piblic funds used by ±e Vanguard 
Public Foundation fcr any pelit.cal activities The renew die un ry terms within he 

agreement ova fh? reporting period The primary reason for thi • Ending was prior tc any significant efforts by 
the Controller s Office - o streamline -'n way reimbursements aie submitted d:e SF Juvenile Probation 
Department adopted a fixed cost reimbi i semenl methodology a.- long a- the budgets were consistent wim the cost 
allocation of said services to be rendered, and that any form cf reimbursement follow ;d general!} accepted 
accoutring pnnciple> Additionally, based oa lack of space t ting documentaaon. an< tc - 

• • : ipy and mail expenses we ask ."41 grantees to maintain all supporting documentation in their fik 
stipulated in their Grant Agreement witb the SF Juvenile P.obatior. Depurment 

•vt to .i significant mat m wording tl er? was a uqm oKtr i in the fomurhnp of the G-l Ml hmlerpbte 
during "hi. reporting period couple with inexperienced staff trying to espe : . ilete the processing of 

eemenl Tiu» agreement was approved by the tad rhe City Attorney Office primarily 

due to the eos t allocation, and all other documents a ; . sociated with said agreement beuig consistent and 
that cb.iilv indicated die total contract amount and what thcmonthlv reimbursement would be. 

The SF Juvenile Probation Department lu- recently adopted a nev fiscal pol 

eapenditu.-es that qualii run i. -euie.it Please let me kix- I -lir 

. . . you 



Lonnie S Hi I . 

D.rertoi ot C omnunitv Services 

SI ravemle Probation Departmenl 



( c '.Villiana Siffermann < hief Pi 



(415 -''--800 75 ' side Avenue im Fraud 



B-3 



Office of the Controller, City Services Auditor 

Ten Selected Organizations Did Not Use City Funds for Political Purposes 

RESIDENTIAL RENT STABILIZATION AND 
ARBITRATION BOARD 



City and County of San Francisco 




Residential Rent Stabilization and 
Arbitration Board 

January 13. 2009 



Ben Rosenfeld 

Controller's Office 

City hall, Room 316 

1 Dr Carlton B. Goodlett PI. 

San Francisco, CA 94102 

Re: Prop Q Audit Report 

Dear Mr. Rosenfeld. 

Our office has received and reviewed your Prop. Q Audit 
Report, and was pleased to see the determination that no City funds 
were used for political purposes. We concur, in whole or in part, with 
the recommendations, and will be working with the Controller's Office 
to put improved processes in place to ensure the appropriateness of 
our grantees' expenditures on a going-forward basis. 

If you have any questions, I can be reached at 252-4650. 

Yours truly, 



M^Mf— 



Delene Wolf 
Executive Director 



24 Hour information Line TEL. (4151 252 4*00 
FAX (415) 252-4699 

■ 



Fa* Back Service (41S) 252-4660 
INTERNET hrtp /.slgov orqj/renlooarcl 



25 Van Ness Avenue »320 
San Francisco. CA 94102-6033 



B-4 



Office of the Controller, City Services Auditor 
Ten Selected Organizations Did Not Use City Funds for Political Purposes 



DEPARTMENT OF BUILDING INSPECTION 



City and County of San Francisco >rf <tvSm&±\>\ Gavin Newsom. Mayor 

Department of Building Inspection iiL^-iSI * Vivian L. Day, C.B.O., Acting Director 



January 8, 2009 



Mr Ben Roser.field 

Controller's Office 

City Hall, Room 316 

1 Dr. Carlton B Goodletl Place 

San Francisco, CA 94102 




Re: Review of Ten Selected Organizations to Determine if City Funds Were Used for 
Political Purposes 

Dear Mr. Rosenfield 

Thank you for the opportunity to review the audit recommendations associated with trie City 
Services Auditor Division's Review of Ten Selected Organizations to Determine if City Funds 
Were Used for Political Purposes " My staff worked closely with yours during preparation of the 
audit and I concur with your recommendations The detaJed response form is attached 

As you are aware, over the past couple of years we have had significant turnover in finance and 
administration staff In 2007 we hired an individual with extensive contract experience It was 
immediately recognized that we needed to ma*e improvements to our contracting policies and 
procedures including development, monitonng and payment processing. Accordingly, our 
finance and administration personnel have worked closely with the rest of the divisions and we 
have made great strides 

With regards to the San Francisco Apartment Association agreement the Housing Inspection 
staff has strengthened their monitoring of the agreements and invoices to ensure services have 
been provided The finance and administration staff is doing rigorous in-depth reviews of the 
invoices and associated documentation. In many cases we have withheld payments until 
sufficient documentation has been submitted to justify the contractor's requests. In addition we 
are reviewing past contract documents 

We met with your staff to review the improved processes to get feedback and we will develop a 
written policy and procedure We plan to review other department's policies and procedures and 
incorporate best practices associated with generally accepted accounting principles and the 
City's policies and procedures 

Please contact me if you require additional information I look forward to continuing lo work with 
you and your staff 




Vivian I Day C BO 
Acting Director 

OFFICE OF THE DIRECTOR 

1660 Mission Street - San Francisco CA 94103 

Ottice (41S) 558-6131 - FAX (415) 558-6225 - www stgov.org/dbi 

Vivian. Day@sfgov org 



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